bodensee.eu
1. The relevant body pursuant to Article 4 of the European General Data Protection Regulation 2016/679 (GDPR) and, simultaneously, the service provider pursuant to the German Telemedia Act (TMG) is Internationale Bodensee Tourismus GmbH (IBT), Hafenstraße 6, D-78462 Konstanz, E-Mail: datenschutz@bodensee.eu, represented by Mr Jürgen Ammann, Managing Director. The following Privacy Policy applies for using the website www.bodensee.eu and the services offered there. You can reach our data protection officer under the mail address datenschutz@bodensee.eu or our postal address adding “Data Protection Officer”.
2. The operators of this website consider the protection of your personal data a very serious matter, especially when it comes to protecting your personal rights during the processing and utilisation of your data. For this reason, we would like to thoroughly inform you about the collection of personal data by using our website. Personal data is any information that identifies you, e.g. your name, your address, e-mail or user behaviour.
3. Our website is not intended for minors and we do not knowingly collect personal data from minors. If persons below the age of 16 years transmit personal data to us, this shall only be permitted if the holder of parental responsibility has consented or authorised the consent of the minor. For this purpose, the contact details of the holder of parental responsibility must be communicated to us in order for us to verify that the holder of parental responsibility has given their consent or authorisation in accordance with Art. 8 (2) of the GDPR. This data and the minor’s data shall then be processed in accordance with this privacy policy.
If we determine that a minor below the age of 16 years has transmitted personal data to us without the holder of parental responsibility having consented or authorised the minor’s consent, we shall delete the data without delay.
4. Generally, the IBT website shall not include any advertising. Should this not be the case, partners’ and service providers’ systems shall also be used to deliver advertising. Some use their own cookies or similar technologies that serve to measure the number of impressions more accurately and to optimise the delivery of advertisements to the user. The data collected for this purpose (AdImpressions, AdClicks) shall be used solely for statistical analysis and shall not include personal data. Cookies that are not under the direct control of IBT may be used to deliver advertising
5. IBT expressly notifies that transmitting data online is subject to security vulnerabilities and cannot be fully protected against access by third parties.
1. The website provider shall automatically collect and store the data your browser automatically transmits in server log files. This shall include the:
This data cannot be associated with a specific person and shall not be combined with data from other sources. We shall reserve the right to review this data if concrete evidence of illegal use becomes known to us.
2. Google Analytics
This website uses Google Analytics, features of Google Inc. (“Google”). Google Analytics uses ‘cookies’, which are text files stored on your computer to help analyse how visitors use the website. The information generated by the cookie about your use of this website is generally transmitted to and stored by Google on servers in the United States.
However, in the event that IP anonymisation should be enabled for this website, Google shall first truncate your IP address if you are located in a member state of the European Union. Only in exceptional cases shall the full IP address be transferred to a Google server in the United States and truncated there. On our behalf, Google shall use this information to analyse your use of the website, to compile reports and to provide us, the operators of the website, with other services related to the use of the website and the Internet.
The IP address transmitted by your browser to Google Analytics shall not be combined with any other Google data.
You may prevent the storage of cookies by selecting the appropriate settings in your browser software. However, please be advised that in so doing you may be unable to use the full functionality of our website. In addition, you may prevent Google from collecting data related to your use of the website generated by a cookie (including your IP address) and processing such data by downloading and installing the browser add-on available at: http://tools.google.com/dlpage/gaoptout?hl=en.
You may prevent Google Analytics from collecting your data by clicking the following link. This will store an opt-out cookie that prevents this website from collecting your data in subsequent visits: Disable Google Analytics.
Further information on Google Analytics’ use of user data is available in Google’s privacy policy: https://support.google.com/analytics/answer/6004245?hl=en.
We have entered into a commissioned data processing agreement with Google and fully implemented the strict requirements of the German data protection authorities for the use of Google Analytics.
This website uses Google Analytics Demographics, which provides information about the age, gender and interests of website visitors. This data stems from Google interest-based advertising and third-party visitor data, and cannot be associated with a specific person. You may disable this feature in your Google Account ad preferences at any time or prevent Google Analytics from collecting your data as described in ‘Objection to data collection’.
This website uses Google Analytics with the ‘_anonymizeIp()’ extension, through which IP addresses are truncated before being processed, excluding the possibility of you being identified personally. Insofar as the data constitutes personal data, this shall be excluded forthwith and the personal data shall be deleted without delay.
In the exceptional cases that personal data is transmitted to the USA, Google is subject to the EU–U.S. Privacy Shield Framework: https://www.privacyshield.gov/EU-US-Framework. The legal grounds for the use of Google Analytics shall be Art. 6 (1) lit. f of the GDPR.
Third-party provider contact details: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland; fax: +353 (1) 436 1001; terms of service: http://www.google.com/analytics/terms/gb.html; safeguarding your data: https://support.google.com/analytics/answer/6004245?hl=e; privacy policy: https://policies.google.com/privacy?hl=en.
3. DoubleClick
This website shall continue using the online marketing tool DoubleClick by Google. DoubleClick uses cookies to serve ads that are relevant to users, improve the campaign performance reports or to prevent a user from viewing the same ads repeatedly. Google uses a cookie ID to track the ads that have been displayed in a specific browser and to prevent them from being displayed more than once. In addition, DoubleClick uses the cookie ID to track conversions that are related to ad requests. This is the case when a user views a DoubleClick ad and later visits the advertiser’s website with the same browser and buys something there. According to Google, DoubleClick cookies contain no personal data.
Due to marketing tools used, your browser automatically establishes a direct connection to Google servers. We have no influence on the extent and further use of the data collected by Google through the use of this tool. Therefore, to the best of our knowledge, we inform you that by integrating DoubleClick, Google is notified that you have accessed the relevant part of our website or clicked an ad on our website. If you are registered with a Google service, Google may allocate your visit to your account. Even if you are not registered or logged in to Google, the provider may obtain and store your IP address.
There are various ways in which you may opt out of this tracking method:
a) configuring the settings of your browser software accordingly enables you to reject third-party cookies in particular, preventing you from receiving ads from third-party providers;
b) disabling cookies that track conversions by setting your browser to block cookies from the domain ‘www.googleadservices.com’;
c) disabling the interest-based ads of providers that are part of the ‘About Ads’ self-regulation campaign by visiting http://www.aboutads.info/choices, which will delete this setting if you delete your cookies;
d) permanently disabling ads in your Firefox, Internet Explorer or Google Chrome browser by visiting http://www.google.com/settings/ads/plugin. However, in this case, please note that you may be unable to fully use all the features of this website.
The legal grounds for the processing of your data shall be Art. 6 (1) lit. f of the GDPR. Further information on Google’s DoubleClick is available at https://www.google.de/doubleclick and http://support.google.com/adsense/answer/2839090.
4. Google Tag Manager
This site additionally uses Google Tag Manager to serve you advertising based on your interests. This allows us to display ads that may be of interest to you, to make our website more interesting for you. For this purpose, statistical information about you is collected and processed by our advertising partners. These ads are identified by the ‘Ads by Google’ that appears on the respective ad.
When you visit our website, Google is notified that you have accessed our website. For this purpose, Google uses a Web beacon to store a cookie on your computer. The data specified in Point 2.1 of this policy shall be transmitted. Neither do we have influence on the collected data nor do we know the full extent of the data collected and the storage period. Your data will be transmitted to the USA and analysed there. If you are logged in to your Google account, your data may be directly allocated to it. If you do not want the data to be allocated to your Google profile, you must log out. This data may be disclosed to contractual partners of Google, third parties and authorities. The legal grounds for the processing of your data shall be Art. 6 (1) lit. f of the GDPR.
There are various ways in which you may prevent the installation of cookies by Google:
Further information about the purpose and extent of the data collected and its processing, as well as your rights in this regard and the configuration settings for the protection of your privacy is available at: Google Inc., 1600 Amphitheatre Parkway, Mountainview, California 94043, USA; Google privacy and terms for advertising: https://policies.google.com/technologies/ads?hl=en.
5. Google Maps
We use the Google Maps service on these web pages. This allows us to display interactive maps directly on the website and provides you with the convenience of the map features. The legal grounds for the use of Google Maps shall be Art. 6 (1) lit. f of the GDPR.
When you visit our website, Google is notified that you have accessed the corresponding page on our website. In addition, the data specified in Point 2.1 of this policy shall be transmitted, regardless of whether a Google account exists, which you are logged in to, or not. If you are logged in to your Google account, your data is allocated directly to your account.
If you do not want the data to be allocated to your Google profile, you must log out before the buttons are enabled. Google stores your data as user profiles and uses these profiles for advertising and/or market research purposes and/or customising its website. In particular, such analysis is carried out (even for users that are not logged in) to provide interest-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles. You must contact Google to exercise this right.
Further information about the purpose and extent of the data collected and its processing by the plug-in provider is available in the privacy policy of the provider. This also includes further information about your rights in this regard and the configuration settings for the protection of your privacy: https://policies.google.com/privacy. Google processes your personal data in the USA and has EU–U.S. Privacy Shield Framework certification: https://www.privacyshield.gov/EU-US-Framework.
6. Google Fonts
We also integrate Google Fonts to display our texts and other content better. The legal grounds for the integration of Google Fonts shall be Art. 6 (1) lit. f of the GDPR.
Further information about the purpose and extent of the data collected and its processing by Google Fonts is available in the privacy policy: https://www.google.com/policies/privacy. You may opt out of any tracking (see Point 2.4) at: https:// adssettings.google.com/authenticated. This also includes further information about your rights in this regard and the configuration settings for the protection of your privacy: https://policies.google.com/privacy. Google processes your personal data in the USA and has EU–U.S. Privacy Shield Framework certification: https://www.privacyshield.gov/EU-US-Framework.
1. General contact with us
Providing us with your personal data by email or through our website (surname, name, email address, postal address) is optional. This data shall be used for the performance of a contract, processing your enquires or orders, conducting our own market or opinion research, and sending our own advertising by post and email. There shall be no further use, in particular, disclosing data to third parties for the purposes of advertising or market or opinion research. We shall delete the data arising in this context once retention is no longer necessary, or restrict the processing in the case that legal retention obligations exist. The legal grounds for this shall be Art. 6 (1) lit. b or Art. 6 (1) lit. f of the GDPR.
2. Newsletter
In order for you to receive the free newsletter distributed by this website, we require your consent in accordance with data protection law, and a valid email address that belongs to you, to which the newsletter shall be sent. Any additional information shall be optional and shall be used to address you directly and to personalise the content of the newsletter, as well as to clarify any issues regarding your email address, if necessary.
We generally use a double opt-in procedure for subscription to our newsletter, that is, we shall only send you the newsletter once you have confirmed your subscription by clicking the link in a confirmation email sent to you specifically for this purpose. This ensures that only you, the owner of the specified email address, may subscribe to the newsletter. You must confirm your subscription shortly after receiving the confirmation email, otherwise your subscription to the newsletter shall be automatically deleted from our database. Your data will be stored exclusively for the purpose of the mailing after your confirmation. The legal grounds for this shall be Art. 6 (1) of the GDPR.
We use rapidmail to send our newsletter. For this purpose, your data shall be disclosed to rapidmail GmbH. rapidmail GmbH shall be prohibited from using your data for any purpose other than that of delivering the newsletter. rapidmail GmbH shall not be permitted to disclose or sell your data. rapidmail is a German, certified newsletter software provider, which has been carefully selected in accordance with the requirements of the GDPR and the BDSG.
You may revoke your consent to the storage of this data and its use for the delivery of the newsletter at any time. For this purpose, please send an email to office@bodensee.eu or click the ‘Unsubscribe’ link in the newsletter.
3. Bodensee Card PLUS
If you would like to order our Bodensee Card PLUS on our website or by email, you are required to provide your personal data for the purpose of processing your order and for the performance of a contract. Obligatory information that is required for the performance of a contract shall be specifically marked with an asterisk on the website, other information is optional. We process the data you provide to process your order. For this purpose, we may disclose your payment details to our bank or online payment service. The legal grounds for this shall be Art. 6 (1) lit. b of the GDPR.
If you wish to purchase the Bodensee Card PLUS at one of our points of sale, you shall also be required to provide personal data both for the purpose of entering into the agreement and for the processing of the agreement. The legal grounds for this shall be Art. 6 (1) lit. b of the GDPR. The points of sale shall collect the data on our behalf and transmit it to our data processing system. They have been carefully selected by us and shall be subject to our directives with regard to data collection. We shall be the controller pursuant to Art. 4 (7) of the GDPR. We have entered into a commissioned data processing agreement with the points of sale in accordance with Art. 28 of the GDPR.
If you wish to use a service of the Bodensee Card PLUS, it shall be necessary that we transmit the personal data required to verify your entitlement for receipt of this service to the respective partner who will perform the service (hereinafter ‘Service Partner’). The legal grounds for the transmission shall be Art. 6 (1) lit. f of the GDPR. Our legitimate interest shall be to prevent misuse of our services and consequently also to protect our Service Partner.
If you make use of a service of a Service Partner, the latter shall collect the data necessary for the provision of the service where applicable. The Service Partner may in turn transmit this data to us. This data may constitute personal data. Generally, this shall involve data related to the use of the services by a person, as well as their age. The legal grounds for the transmission shall be Art. 6 (1) lit. f of the GDPR. Our legitimate interest in the transmission of this data shall be to improve the services by analysing their use. We shall be the controller pursuant to Art. 4 (7) of the GDPR. We have entered into a commissioned data processing agreement with the Service Partner in accordance with Art. 28 of the GDPR. There shall be no further use of the data by the Service Partner.
The data transmission in accordance with Point 3.3 shall take place exclusively within countries that are party to the European Economic Area (EEA) Agreement or Switzerland. In a decision in accordance with Art. 45 of the GDPR, the European Commission has decided that Switzerland ensures an adequate level of data protection.
In addition, we may also process the data you provide to inform you about other interesting products in our portfolio or to send you emails with technical information. The legal grounds for this shall be Art. 6 (1) of the GDPR.
Your data shall only be used for as long as required for the existing customer relationship. Irrespective of this, we are obliged by commercial and tax law to store your address, payment and order details for a period of 10 years.
We use feratel as our technical system provider to issue and use the Bodensee Card PLUS. Therefore, your data shall be transmitted to feratel media technologies AG. The service provider shall be appointed for the purpose of our legitimate interests in accordance with Art. 6 (1) lit. f of the GDPR. feratel media technologies AG shall not be permitted to use your data for purposes other than for the processing of the BodenseeErlebniskarte / Bodensee Card PLUS. feratel media technologies AG shall not be permitted to disclose or sell your data. We have entered into a commissioned data processing agreement with feratel media technologies AG and fully implemented the strict requirements of the German data protection authorities for the use of feratel Card Systems. Further information about data protection at feratel media technologies AG is available at https://www.feratel.com/en/privacy-policy.html.
4. Careers page
Within the scope of our careers page, you may apply for specific vacancies at Bodensee Tourismus GmbH. Your data (name, email address, contact details, application documents) shall only be processed for the purpose of the respective vacancy (Art. 6 [1] lit. b of the GDPR, Section 26 of the German Federal Data Protection Act [BDSG]) or of other vacancies, to which you have consented (Art. 6 [1] lit. a of the GDPR). If you have consented to the processing of your application data, you may withdraw your consent at any time.
Note on sensitive data: We expressly inform you that applications, in particular CVs, certificates and other information you transmit to us may contain particularly sensitive information about mental and physical health, racial or ethnic origin, political opinion, religious or philosophical persuasion, membership in a trade union or political party, or sexual preference.
Should you transmit such information to us in your online application, you shall expressly consent to our processing of this data for the purpose of the application. The processing of this data shall be in accordance with this Privacy Policy and any other relevant legislation.
The data transmitted shall be erased in the event of rejection or a decision not to pursue your application no earlier than three months after the conclusion of the application process. This shall not apply if legal provisions oppose erasure or if retention is required for evidential purposes or you have consented to longer retention.
We use HRworks as the technical system provider of the applicant management. Your data will therefore be transferred to HRworks GmbH. The service provider is used on the basis of our legitimate interests pursuant to Art. 6 Para. 1 lit. f DSGVO. HRworks GmbH is prohibited from using your data for purposes other than the application process and the subsequent recruitment, if applicable. HRworks GmbH is not permitted to pass on or sell your data. We have concluded an order data processing contract with HRworks GmbH and fully implement the strict requirements of the German data protection authorities when using the system. Further information on data protection at HRworks GmbH can be found at www.hrworks.de/unternehmen/datenschutz.
Vacancies of tourism partners of Bodensee Tourismus GmbH are also listed on our careers page. These shall be clearly labelled as ‘Other tourism partner vacancies’. These applications shall be addressed directly to the relevant partner, whose privacy policy shall apply.
5. Competitions
In competitions, we use your data (name, contact details) for the purpose of notifying winners (Art. 6 [1] lit. b of the GDPR) and advertising our services by post (Art. 6 [1] lit. f of the GDPR) or by email with your consent (Art. 6 [1] lit. a GDPR). For additional information, please refer to the participation terms and conditions of the respective competition.
6. Mediation of hotel and leisure offers
When arranging hotel and leisure offers, your data (first name, surname, address) is transmitted to the service provider (Art. 6 para. 1 lit. b DSGVO). Your data will not be stored by us.
The agreement for the use of these services shall be entered into between you and the service provider, in each specific case by express agreement or use of the services. The contractual basis for the provision of the services by the service providers shall be the terms and conditions and the general provisions of the services of the service providers in each specific case, insofar as these have become effective terms of the agreement in accordance with legal provisions. Internationale Bodensee Tourismus GmbH shall constitute neither a contractual partner with regard to the services to be provided nor an agent of the relevant agreements. In particular, it shall not constitute a tour operator.
1. Insofar as you have provided your personal data to us, this shall not be disclosed to third parties in principle. This shall be disclosed only:
2. Social plug-ins are used on this website. Social plug-ins are web applications that connect this site to selected social networks. However, the social plug-ins are not directly integrated but must first be enabled by a separate click. Only when they are enabled shall a connection to the social network be established, regardless of whether you actually click on the social plug-ins. Your IP address and user data of the respective social network may be transmitted through this connection. Please refer to Point 6 for details about the social plug-ins used.
This website uses SSL encryption for security purposes and to securely transmit sensitive information such as queries to us, the operators of the website. When you use an encrypted connection, the URL of the website starts with ‘https’ rather than ‘http’ and the lock icon appears in your browser’s address bar.
If SSL encryption is enabled, any data that you submit to us cannot be read by third parties.
Our website uses various cookies, which are small text files that your browser stores on your computer. If you revisit a website, these cookies provide information for the website to automatically recognise you. Cookies do not contain viruses and do not harm your computer. IBT shall only use cookies when they are urgently required for user functions or to facilitate navigation through the website. Information shall not be made available to any third party, since cookies shall only be used for the purposes set out above. Most browsers are set to automatically accept cookies. You may set your browser to inform you when there is an attempt to store a cookie on your computer and to only accept such cookies on a case-by-case basis, to accept cookies in specific cases or to generally reject cookies, or to automatically delete all cookies when you close your browser. Disabling cookies may restrict the functionality of this website.
IBT shall store your data on highly secure servers in Germany. These may only be accessed by a limited number of people authorised by IBT involved with the technical, commercial or administrative support of the servers.
1. Our website contains social plug-ins and links to the social networks Facebook, Twitter, YouTube, Google+ and Instagram. No data transfer shall take place in the case of links.
The following privacy policies shall apply for social plug-ins:
2. Facebook
We use the ‘Like’ as well as the ‘Share’ buttons (‘Facebook plug-ins’) of Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irland (‘Facebook’), which connect this website to Facebook’s social network. Further information about the functionality and appearance of the Facebook plug-ins is available at http://developers.facebook.com/docs/plugins.
By enabling the Facebook plug-ins, your browser establishes a direct connection to Facebook’s servers. The content of Facebook plug-ins is transmitted directly from Facebook to your browser. Certain data is simultaneously transmitted from your browser to Facebook. This occurs regardless of whether you click the Facebook plug-ins or not. We have no influence on the extent of the data that Facebook collects in this manner. To the best of our knowledge, this includes the following data:
The purpose and extent of the data collected, its further processing and use by Facebook, and your relevant rights and configuration settings to protect your privacy are available in Facebook’s data policy: https://www.facebook.com/about/privacy. You shall have the right to object to the creation of these user profiles. You must contact Facebook to exercise this right. The legal grounds for the use of Facebook social plug-ins shall be Art. 6 (1) lit. f of the GDPR.
If you are a Facebook member and do not want Facebook to collect data about you from our website and link it to the data stored in your Facebook account, you must log out of Facebook before visiting our website and delete any existing Facebook cookies. In addition, Facebook plug-ins may also be blocked using your browser’s add-ons. Further information is available on your browser’s add-on pages.
3. Twitter
We use the Tweet button of Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, USA (‘Twitter’) to connect to Twitter. Further information about the functionality and appearance of the Tweet button is available at https://developer.twitter.com/en/docs/twitter-for-websites/tweet-button/faqs.
By enabling (cf. Point 4.2) the Tweet button, your browser establishes a direct connection to Twitter’s servers. The content of the plug-in is transmitted directly from Twitter to your browser. Certain data is simultaneously transmitted from your browser to Twitter. This occurs regardless of whether you click the Tweet button or not. We have no influence on the extent of the data that Twitter collects in this manner. To the best of our knowledge, this includes the following data, in particular, for displaying the Tweet button:
To prevent Twitter from collecting your data, the Tweet button may also be hidden using browser add-ons. The legal grounds for the use of the Tweet button shall be Art. 6 (1) lit. f of the GDPR.
4. YouTube
We use the video service of YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA (‘YouTube’) to display our videos. The legal grounds for this shall be Art. 6 (1) lit. f of the GDPR.
If YouTube videos are directly integrated into our website, YouTube sends the content of the embedded videos directly to your browser. Certain data is simultaneously transmitted from your browser to YouTube. This occurs regardless of whether you click the video or not. We have no influence on the extent of the data that YouTube collects in this manner. To the best of our knowledge, this includes the following data, in particular, for displaying YouTube videos:
To prevent YouTube from collecting your data, the embedded YouTube videos may also be hidden using browser add-ons. If you are logged in to your Google account, your data is allocated directly to your account. If you do not want the data to be allocated to your YouTube profile, you must log out before the buttons are enabled. YouTube stores your data as user profiles and uses these profiles for advertising and/or market research purposes and/or customising its website. In particular, such analysis is carried out (even for users that are not logged in) to provide interest-based advertising and to inform other users of the social network about your activities on our website. You have the right to object to the creation of these user profiles. You must contact YouTube to exercise this right.
Further information about the purpose and extent of the data collected and its processing by YouTube is available in the privacy policy of the provider. This also includes further information about your rights and the configuration settings for the protection of your privacy: https://policies.google.com/privacy. Google processes your personal data in the USA and has EU–U.S. Privacy Shield Framework certification: https://www.privacyshield.gov/EU-US-Framework.
5. Instagram
We may integrate features and content of the Instagram service of Instagram Inc., 1601 Willow Road, Menlo Park, CA, 94025, USA, into our website. These may include content such as images, videos or texts, and buttons with which users may indicate that they like the content or subscribe to the authors of the content or to our posts. The legal grounds for this shall be Art. 6 (1) lit. f of the GDPR. If users are members of the Instagram platform, Instagram may allocate the retrieval of the aforementioned content and features to their users’ profiles. Instagram privacy policy: http://instagram.com/about/legal/privacy.
Your data shall only be used for as long as required for the existing customer relationship unless you have consented or we have a legitimate interest to process it further. In these cases, we shall process your data until you withdraw your consent or object to our legitimate interests. Irrespective of this, we are obliged by commercial and tax law to store your address, payment and order details for a period of 10 years.
You shall have the right to freely access your stored personal data, its origin and recipients, the purpose for which it is processed. You shall also have the right:
For this purpose and for further information on personal data, you may contact us at Internationale Bodensee Tourismus GmbH, Hafenstraße 6, D-78462 Konstanz, or datenschutz@bodensee.eu.
You shall also have the right to lodge a complaint about the processing of your personal data by us with a data protection supervisory authority.
Data that is absolutely necessary for processing an order or for commercial purposes may only be deleted once the order has been processed. Please be advised that we shall no longer be able to provide a personalised service if you delete or block your data, since such service is based on the use of customer data.
We hereby object to the use of the contact details published in terms of our obligation to publish a legal notice (‘Imprint’) for the purpose of sending unsolicited advertising and information material. The operators of the website shall expressly reserve the right to take legal action in the event that unsolicited promotional information such as spam is sent.